Annual OSHA Refresher Training Requirements

January 2, 2014 - Can you believe that 2014 is here already? It seems like only yesterday we were all worried about a Y2K-triggered meltdown of our computer systems. And while that non-event passed us by many years ago without so much as a fizzle, there is one other issue that does require your full attention each and every year; identifying OSHA standards that require mandatory annual refresher training for employees.

Most everyone who has visited our website knows that we have place links to excerpts of all Federal OSHA references to OSHA training in General Industry and Construction standards; we even referenced indirect phrases such as “the employer shall inform employees” or “competent person” which can imply some level of training or information. These pages get hundreds of views every day, and are a great resource to help identify your overall OSHA training requirements.

But since we are here at the beginning of a brand new year, I thought it might also be helpful to our readers if I went back through all of those standards and pulled out the ones that specifically require employers to provide their workers with mandatory refresher training or information annually and make a table that lists them in this month’s blog post.

The training program shall be repeated annually for each employee included in the hearing conservation program. Information provided in the training program shall be updated to be consistent with changes in protective equipment and work processes.

Refresher training. Employees specified in paragraph (e)(1) of this section, and managers and supervisors specified in paragraph (e)(4) of this section, shall receive eight hours of refresher training annually on the items specified in paragraph (e)(2) and/or (e)(4) of this section, any critique of incidents that have occurred in the past year that can serve as training examples of related work, and other relevant topics.

New employees. The employer shall develop and implement a training program which is part of the employer's safety and health program, for employees exposed to health hazards or hazardous substances at TSD operations to enable the employees to perform their assigned duties and functions in a safe and healthful manner so as not to endanger themselves or other employees. The initial training shall be for 24 hours and refresher training shall be for eight hours annually. Employees who have received the initial training required by this paragraph shall be given a written certificate attesting that they have successfully completed the necessary training.

Those employees who are trained in accordance with paragraph (q)(6) of this section shall receive annual refresher training of sufficient content and duration to maintain their competencies, or shall demonstrate competency in those areas at least yearly.

The employer shall assure that training and education is conducted frequently enough to assure that each member of the fire brigade is able to perform the member's assigned duties and functions satisfactorily and in a safe manner so as not to endanger fire brigade members or other employees. All fire brigade members shall be provided with training at least annually. In addition, fire brigade members who are expected to perform interior structural fire-fighting shall be provided with an education session or training at least quarterly.

The employer shall train employees designated to inspect, maintain, operate, or repair fixed extinguishing systems and annually review their training to keep them up-to-date in the functions they are to perform.

The operator training required by paragraph (f)(2) of this section shall be provided to the employee before the employee initially operates the press and as needed to maintain competence, but not less than annually thereafter. It shall include instruction relative to the following items for presses used in the PSDI mode.

(i) The employer shall train each employee who is exposed to airborne concentrations of asbestos at or above the PEL and/or excursion limit in accordance with the requirements of this section. The employer shall institute a training program and ensure employee participation in the program.

(ii) Training shall be provided prior to or at the time of initial assignment and at least annually thereafter.

(iv) The employer shall also provide, at no cost to employees who perform housekeeping operations in an area which contains ACM or PACM, an asbestos awareness training course, which shall at a minimum contain the following elements: health effects of asbestos, locations of ACM and PACM in the building/facility, recognition of ACM and PACM damage and deterioration, requirements in this standard relating to housekeeping, and proper response to fiber release episodes, to all employees who perform housekeeping work in areas where ACM and/or PACM is present. Each such employee shall be so trained at least once a year.

(ii) The training program shall be provided by October 1, 1978, for employees covered by this provision, at the time of initial assignment for those subsequently covered by this provision, and at least annually for other covered employees thereafter; and the employer shall assure that each employee is informed of the following . . .

The employer shall provide employees with information and training at the time of their initial assignment to a work area where benzene is present. If exposures are above the action level, employees shall be provided with information and training at least annually thereafter.

The training program shall be provided at least annually for all employees who are employed in the regulated area, except that training regarding the occupational safety and health hazards associated with exposure to coke oven emissions and the purpose, proper use, and limitations of respiratory protective devices shall be provided at least quarterly until January 20, 1978.

The training program shall be provided prior to initial assignment and shall be repeated annually for each employee exposed to cotton dust, when job assignments or work processes change and when employee performance indicates a need for retraining.

Training shall be provided at the time of initial assignment, or upon institution of the training program, and at least annually thereafter, and the employer shall assure that each employee is informed of the following:

(A) - The information contained in appendixes A and B;

(B) - The quantity, location, manner of use, release, or storage of AN, and the specific nature of operations which could result in exposure to AN, as well as any necessary protective steps;

(C) - The purpose, proper use, and limitations of respirators and protective clothing;

(D) - The purpose and a description of the medical surveillance program required by paragraph (n) of this section;

(E) - The emergency procedures developed, as required by paragraph (i) of this section;

(F) - Engineering and work practice controls, their function, and the employee's relationship to these controls; and

The employer shall provide employees who are potentially exposed to EtO at or above the action level or above the excursion limit with information and training on EtO at the time of initial assignment and at least annually thereafter

Frequency. Employers shall provide such information and training to employees at the time of initial assignment, and whenever a new exposure to formaldehyde is introduced into the work area. The training shall be repeated at least annually.

Training shall be provided prior to or at the time of initial assignment to a job potentially involving exposure to BD at or above the action level or STEL and at least annually thereafter.

Important caveats to keep in mind:

First of all, this list only addresses those Federal OSHA standards that directly require the employer to provide affected workers with training or information at least once a year, and does not include those standards that may require refresher training in special cases (see related blog), such as when certain program procedures or equipment are changed, or when an annually required program/procedure review require an overview of the procedures and/or refresher training (e.g.: electric power generation, transmission and distribution, forklift operator evaluation . . .);

The list does not include the requirement in the "Control of Hazardous Energy" standard (1910.147) for employers to review applicable lockout/tagout procedures annually with authorized workers.

This list also does not show standards that require refresher training at longer time intervals (e.g.: the Process Safety Management (PSM) standard requires refresher training every three years);

Nor does it address those standards that incorporate by reference specific training sponsored by a specific organization that might require annual refresher training (e.g.: Red Cross first aid or CPR classes);

In addition, this table does not list any OSHA standards that reference other standards which require annual refresher training (e.g.: the overhead crane standard requires employees using portable fire extinguishers be trained per 1910.157, but it does not specifically mention the annual refresher specifically required in 1910.157);

And it does not address the annual “practice” drill using simulated rescue operations required for employees who perform permit-required confined space rescue services;

Also, the construction standards requiring annual refreshers are the same ones as the corresponding general industry regulations;

And last but not least; keep in mind that these references apply to federal OSHA regulations only; there are a few (but not many) State OSHA standards that may require annual refresher training on a topic that Federal OSHA does not (e.g.: annual refresher on hazard communication required by MN-OSHA).

Were you surprised by the list? Was there a specific federal OSHA standard that you though required annual refresher training but actually does not? Or perhaps you just learned of one that does require annual training that you were not aware of until now?

If so, or if you know of another federal OSHA standard not appearing on the list that specifically requires annual training, please share your comments with us in the “Comments” section of this post by clicking here and then scrolling down the page to the “Comments” box. You can also tread other reader comments at that link. And last but not least, I encourage you to Share This Blog Post with Others in Your Network who might benefit from reading this post.

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